On 12 March 2025, the US Securities and Exchange Commission (SEC) staff issued a no-action letter that provides private fund sponsors with a concrete, streamlined approach to relying on Rule 506(c), based on minimum...more
Almost exactly two years after enactment in the Tax Cuts and Jobs Act, Treasury has released final regulations on the Opportunity Zone (“OZ”) tax incentive. ...more
DEVELOPMENTS IN SEEDING ARRANGEMENTS – OVERVIEW -
- Seeding Arrangements Fall Along a Spectrum, with Features Including:
- Making a Significant Capital Commitment to a Fund Manager at the Initial Closing of the Fund
-...more
OVERVIEW OF OZ RULES -
- The OZ program was created by the Tax Cuts and Jobs Act, enacted in December 2017 to help direct economic resources to low income communities, spurring economic growth and job creation.
- The...more
Restoring accountability measures stripped during tax reform could be good news for those concerned about gentrification but may result in reputational risks and additional costs for OZ Funds -
As we anticipated in our...more
After a lengthy drafting and protracted review process, the Department of Treasury (“Treasury”) has released its second set of proposed regulations (the “Second Round Regs”) providing guidance on the implementation of the...more
5/6/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
In December 2017, Congress enacted The Tax Cuts and Jobs Act (the “Tax Cuts Act”). Included in that tax legislation is what has come to be called the opportunity zone incentive (“OZ Incentive”): a host of dramatic new tax...more